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HIPAA Interim Final Rule, October 30, 2009

Client Alert | less than 1 min read | 11.06.09

On October 30, 2009, the Department of Health and Human Services (HHS) published an interim final rule conforming HIPAA's enforcement regulations to revisions made under the HITECH Act. The interim final rule strengthens HHS' civil money penalty authority by establishing categories of violations reflecting levels of culpability, increasing the civil penalty amounts, and modifying the affirmative defenses available to covered entities.

Click here to view a presentation on the HIPAA Final Rule [PDF]

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Client Alert | 3 min read | 07.13.26

Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below....